---------- Forwarded message ---------- From: Tim - N3TL Date: Tue, Feb 23, 2010 at 3:58 PM
Following is the complete text of the request I made to the FCC for a ruling on ROS use on HF by licensed U.S. amateurs, along with the response from the FCC I just received. As part of my request, I provided PDF copies of two documents that Jose has prepared and made available on the ROS blog site: 1 – His user guide for the software. 2 – His description of the mode. Please see below: Summary* : Request for clarification of new amateur radio digital mode Description* : Within the past week, a new digital mode - called ROS - has surfaced on the HR amateur bands. Its creator refers to it as spread spectrum, but there is some debate over whether the mode truly represents spread spectrum as defined by the FCC. I am writing to request a review of the creator's documentation, which I have attached, and a formal ruling on whether this mode is legal for use below 222 mHz by licensed U.S. amateurs. It would be very helpful if the FCC, upon completion of this review, would distribute a public announcement of its determination to appropriate amateur radio and media outlets. Thank you very much in advance for your time and prompt attention to this request. I look forward to hearing from you soon. Sincerely, Timothy J. Lilley - N3TL Solution Details : Dear Mr. Lilley, Section 97.305 is the rule that specifies where different emission types are allowed to be transmitted on different bands. "ROS" is viewed as "spread spectrum," and the creator of the system describes it as that. We assume that he knows what he created. 97.305 authorizes spread spectrum emission types (defined in Section 97.3) to be transmitted by FCC licensed amateur stations at places we regulate communications only on 222-225 MHz and higher frequency amateur bands. European telecommunication regulatory authorities may authorize amateur stations in Europe to use SS on the HF bands, but this is of no concern to us. The Commission does not determine if a particular mode "truly" represents spread spectrum as it is defined in the rules. The licensee of the station transmitting the emission is responsible for determining that the operation of the station complies with the rules. This would include determining the type of emission the station is transmitting and that the frequencies being used are authorized for that type of emission. Should you have any further questions, or need additional information, please contact the ULS Customer Support Hotline at (877) 480-3201, selecting option 2. Sincerely, Agent 3820 I have discontinued further experimentation with ROS. 73, Tim – N3TL [image: Yahoo! Groups]<http://groups.yahoo.com/;_ylc=X3oDMTJlN2tnNGpuBF9TAzk3NDc2NTkwBGdycElkAzQxMTE5NDUxBGdycHNwSWQDMTcwNTA2MzEwOARzZWMDZnRyBHNsawNnZnAEc3RpbWUDMTI2Njk1ODcyMw--> Switch to: Text-Only<rosdigitalmodemgroup-traditio...@yahoogroups.com?subject=change+delivery+format:+Traditional>, Daily Digest<rosdigitalmodemgroup-dig...@yahoogroups.com?subject=email+delivery:+Digest>• Unsubscribe<rosdigitalmodemgroup-unsubscr...@yahoogroups.com?subject=unsubscribe>• Terms of Use <http://docs.yahoo.com/info/terms/> .
